USDA Animal Care Policy, PHS Policy on Humane Care and Use of Animals, and the Guide for the Care and Use of Laboratory Animals (the Guide) all reference the need for euthanasia methods to be consistent with the AVMA Guidelines for the Euthanasia of Animals. In October 2017, the section on Euthanasia in USDA Animal Care Policy #3 was revised to say, “Appropriate methods may include, but are not limited to, those described in the ‘AVMA Guidelines for Euthanasia of Animals.’” The addition of the words “but are not limited to” effectively recognizes the IACUC as the body authorized to determine whether proposed methods constitute appropriate methods of euthanasia and de-emphasizes the perceived requirement to adhere solely to the AVMA guidelines.

It is important to note that to date there have been no changes to PHS Policy IV.C.1.g regarding euthanasia, which states that “methods of euthanasia used will be consistent with the recommendations of the American Veterinary Medical Association (AVMA) Panel on Euthanasia, unless a deviation is justified for scientific reasons in writing by the investigator.” Therefore, if activities in question are covered by the organization’s PHS Assurance, it is important that the IACUC take the additional step of reviewing and approving a deviation from a “should” statement in the Guide and including it on the semiannual report to the Institutional Official.